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PAIA Manual

Last updated 13 April 2026

Prepared in terms of section 51 of the Promotion of Access to Information Act, 2 of 2000 (as amended).

1. Introduction

This manual has been prepared in terms of section 51 of the Promotion of Access to Information Act, 2 of 2000, as amended ("PAIA").

The purpose of this manual is to assist requesters to:

  • understand the types of records held by Olio Technologies (Pty) Ltd trading as Brewster;
  • know how to request access to those records in terms of PAIA;
  • understand how personal information is processed by the organisation; and
  • identify the contact details of the Information Officer for purposes of PAIA and POPIA.

2. Details of the Private Body

Name of Private Body: Olio Technologies (Pty) Ltd trading as Brewster
Trading Name: Brewster
Registered Address: 11 Greyvenstein Close, Plattekloof Glen, Cape Town, South Africa, 7460
Website: https://brewster.co.za
General Email: [email protected]
Support Email: [email protected]

3. Information Officer Details

Information Officer: Tyrone Smith
Email: [email protected]
General PAIA / POPIA Contact: [email protected]
Physical Address: 11 Greyvenstein Close, Plattekloof Glen, Cape Town, South Africa, 7460

No Deputy Information Officer is listed in this manual at present. If one or more Deputy Information Officers are designated in future, their details may be added in an updated version of this manual.

4. Guide on How to Use PAIA

The Information Regulator has made available a guide on how to use PAIA and how to obtain access to records in terms of PAIA and POPIA.

Requesters may obtain the guide from the Information Regulator.

Information Regulator (South Africa)
Website: https://inforegulator.org.za/
General enquiries: [email protected]
Telephone: 010 023 5200
Toll Free: 0800 017 160
POPIA complaints: [email protected]
PAIA complaints: [email protected]
Physical address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191

5. Categories of Records Automatically Available Without a Formal PAIA Request

The following categories of records may be available without a formal PAIA request, subject to availability and applicable website access:

  • public website content;
  • published legal policies, including the Privacy Policy, Terms of Service, Cookie Policy, Customer Refund Policy, and Merchant Platform Rules;
  • marketing and product information made available on the Brewster website;
  • public contact information; and
  • other records or notices that Brewster chooses to make publicly available from time to time.

These records may generally be accessed through the website or by contacting Brewster using the contact details in this manual.

6. Records Available in Terms of Other Legislation

Where applicable, records may also be available in terms of legislation including, without limitation:

  • Companies Act, 2008;
  • Protection of Personal Information Act, 2013;
  • Promotion of Access to Information Act, 2000;
  • Electronic Communications and Transactions Act, 2002;
  • Consumer Protection Act, 2008;
  • Labour Relations Act, 1995;
  • Basic Conditions of Employment Act, 1997;
  • Employment Equity Act, 1998;
  • Occupational Health and Safety Act, 1993;
  • Income Tax Act, 1962; and
  • Value-Added Tax Act, 1991.

This section does not create an automatic right of access to records, but indicates that certain records may exist in terms of applicable legislation.

7. Categories of Records Held by Brewster

Brewster may hold records including, without limitation, the following categories:

7.1 Corporate and Administrative Records

  • company registration and statutory records;
  • internal governance and operational records;
  • contracts and commercial agreements;
  • policies, standards, and procedures; and
  • financial and accounting records.

7.2 Human Resources Records

  • employee records;
  • contractor records;
  • recruitment records;
  • payroll-related records; and
  • internal HR administration records.

7.3 Customer and User Records

  • customer account records;
  • merchant and store account records;
  • staff user and access records;
  • order records;
  • support and communication records;
  • billing and subscription records; and
  • refund, reversal, dispute, and remittance-related records.

7.4 Technical and Platform Records

  • system logs;
  • audit records;
  • security and access logs;
  • incident and support records;
  • platform analytics in anonymised or aggregated form where applicable; and
  • service configuration and operational records.

7.5 Third-Party and Commercial Records

  • supplier records;
  • service provider records;
  • payment-provider-related records;
  • merchant onboarding and due diligence records; and
  • records relating to integrations with third-party providers.

8. How to Request Access to Records

A requester seeking access to a record of Brewster must complete the prescribed PAIA request form and submit it to the Information Officer using the contact details in this manual.

The requester should provide sufficient detail to enable Brewster to identify:

  • the record or records requested;
  • the requester's identity and contact details;
  • the right the requester seeks to exercise or protect, where required for a private body request; and
  • the form of access requested, where applicable.

Brewster will process requests in accordance with PAIA and may require payment of any prescribed request fee or access fee where applicable.

9. Grounds for Refusal of Access

Access to records may be refused on one or more grounds permitted by PAIA, including where access would involve the unreasonable disclosure of personal information of a third party, confidential commercial information, legally privileged records, or records whose disclosure is otherwise restricted by law.

Brewster will assess each request in accordance with PAIA and any applicable grounds of refusal.

10. Remedies Available to a Requester

If a requester is dissatisfied with Brewster's decision in relation to a PAIA request, the requester may exercise any remedy available in law, including lodging a complaint with the Information Regulator or applying to a court where appropriate.

11. Processing of Personal Information

Brewster processes personal information in connection with its website, customer application, merchant and admin platform, support processes, billing, payment enablement, security, and related business operations.

11.1 Purpose of Processing

Brewster may process personal information for purposes including:

  • account creation and administration;
  • authentication and access control;
  • order placement and fulfilment workflows;
  • merchant onboarding and store setup;
  • billing, subscriptions, remittance, and payment support;
  • customer support and communications;
  • security, fraud prevention, and audit logging;
  • service improvement and anonymised analytics; and
  • legal and regulatory compliance.

11.2 Categories of Data Subjects

  • website visitors;
  • customers;
  • merchant owners and administrators;
  • merchant staff users;
  • employees and contractors;
  • suppliers and service providers; and
  • business contacts and prospective customers.

11.3 Categories of Personal Information

  • identification and contact details;
  • account and authentication data;
  • order and transaction data;
  • billing and subscription information;
  • technical and usage information;
  • support and communications records; and
  • other information reasonably required for platform operation and compliance.

11.4 Recipients or Categories of Recipients

Brewster may share personal information with categories of recipients including:

  • authorised internal personnel;
  • merchant users and store staff where necessary for order handling;
  • payment providers and billing providers;
  • hosting, support, security, and infrastructure providers;
  • professional advisors; and
  • regulators, courts, or authorities where legally required.

11.5 Cross-Border Transfers

Brewster is designed so that personal information is encrypted and remains hosted within South Africa as part of normal platform operations.

If cross-border processing becomes necessary in a specific case, Brewster will take reasonable steps to ensure adequate protection in accordance with applicable law.

11.6 Security Measures

Brewster applies reasonable technical and organisational measures to protect personal information, including access controls, authentication controls, encryption, logging, monitoring, and related safeguards appropriate to the nature of the information processed.

12. Availability of This Manual

This manual is made available in accordance with PAIA. It may be published on Brewster's website and may also be requested from the Information Officer.

13. Updating of This Manual

Brewster may update this manual from time to time to reflect changes in law, business operations, records, contact details, or processing activities.